Acórdão do FIFA, processo FPSD-20986 GLYNOS_2026-03-24

Data

24/03/2026

Fonte

inside.fifa.com

Labour Disputes

Texto da decisão

REF. FPSD-20986

Decision of the
Dispute Resolution Chamber
passed on 24 March 2026
regarding an employment-related dispute concerning the player Spyridon
Glynos

BY:
Andre DOS SANTOS MEGALE, Brazil

CLAIMANT:
Spyridon Glynos, Greece
Represented by Loizos Hadjidemetriou

RESPONDENT:
Paeek Kerineias, Cyprus

pg. 2

REF. FPSD-20986

I. Facts of the case
1.

On 19 April 2024, the Greek player, Spyridon Glynos (hereinafter: the Player or the Claimant),
and the Cypriot club, Paeek Kerineias (hereinafter: the Club or the Respondent), entered into
an employment contract (hereinafter: the Contract) valid as from 1 August 2024 until 30
April 2025.

In accordance with the Contract, the Respondent undertook to pay to the Claimant, inter
alia, the following amounts, quoted verbatim:
“1.3. The Player’s basic gross salary will be paid as follows:
1.3.1 For the 2024-25 footballing season
From 01/08/2024 until 30/04/2025, € 614,00 per month (€ 500,00 net) and the subsequent
payments on the 30th day of each month with the last on the 30th of April 2025.
1.3.2 For the 2025-26 footballing season:
In the event that the team will compete in the first division from 01/08/2025 until 30/05/2026,
€ 1.114,00 per month (€1.000,00 net) and the subsequent payments on the 30th day of each
month with the last one being on the 30th of May 2025.
All payable taxes to the Tax Commissioner under the applicable legislation will be paid by the
[Club].”

Further, on 19 April 2024, the Player and the Club entered into an image rights agreement
(hereinafter: the IRA). The IRA provided the following with respect to the term, quoted
verbatim:
“5. This agreement is terminated:
5.1 By mutual consent of the parties.
5.2 Upon the termination, for any reason, of the employment agreement between the Player
and the [Club].”

In accordance with Annex 1 of the IRA, the Club undertook to pay, inter alia, the following
amounts:
a.

EUR 11,700 to the Player for the 2024/2025 season as remuneration for the image
rights.

EUR 400 per month for the months of January to April in the 2024/2025 season as
additional remuneration for the image rights if the Club participates in “Group A”.

EUR 37,000 to the Player for the 2025/2026 season as remuneration for the image
rights if the Club remained in the first division.

pg. 3

REF. FPSD-20986

EUR 150 to cover personal expenses.

EUR 50 as bonus for every win, providing he scored a goal.

EUR 30 as bonus for every win, providing he provided an assist.

Roundtrip tickets from/to Athens, accommodation, a car and five dinners per week.

Bonuses as per the football performance of the Player.

On 2 June 2025, the Claimant (along with a few teammates) put the Respondent in default
of payment of monthly salaries under the Contract and IRA, amounting to EUR 7,030, and
set a time limit of 10 days in order to remedy the default.

II. Proceedings before FIFA
6.

On 23 September 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Position of the Claimant

The Player argued that the Club failed to pay him salaries and bonuses under the Contract
and the IRA, amounting to EUR 7,030 net, and corresponding to the following amounts,
despite being put in default and being granted 10 days to comply with its financial
obligations:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.

EUR 1,200 net as part of the February 2025 salary.
EUR 2,200 net representing the March 2025 salary.
EUR 2,200 net representing the April 2025 salary.
EUR 150 net representing the August 2024 personal allowance.
EUR 150 net representing the September 2024 personal allowance.
EUR 150 net representing the October 2024 personal allowance.
EUR 150 net representing the November 2024 personal allowance.
EUR 150 net representing the December 2024 personal allowance.
EUR 150 net representing the January 2025 personal allowance.
EUR 150 net representing the February 2025 personal allowance.
EUR 150 net representing the March 2025 personal allowance.
EUR 150 net representing the April 2025 personal allowance.
EUR 50 for scoring a goal that led to a win on 22 November 2024.
EUR 30 for providing an assist that led to a win on 26 October 2024.

The Claimant’s requests for relief were the following, quoted verbatim:

pg. 4

REF. FPSD-20986

“1. The Claimant requests the FIFA DRC to order the Respondent to pay the Claimant, in the
bank account seen in exhibit 2, the following amounts:
i. EUR 7,030 net, plus legal interest from the date when each payment became due, until full
settlement.”
b. Position of the Respondent
9.

The Respondent failed to reply to the claim despite being invited to do so.

pg. 5

REF. FPSD-20986

III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
10. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether he was competent to deal with the case at hand. In this respect, he took
note that the present matter was presented to FIFA on 23 September 2025 and submitted
for decision on 24 March 2026. Taking into account the wording of arts. 32 and 35 of the
January 2026 edition of the Procedural Rules Governing the Football Tribunal (hereinafter:
the Procedural Rules), the aforementioned edition of the Procedural Rules is applicable to
the matter at hand.
11. Furthermore, the Single Judge referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations on the Status and Transfer of Players (hereinafter: the Regulations) (July 2025
edition), the Dispute Resolution Chamber is competent to deal with the matter at stake,
which concerns an employment-related dispute with an international dimension between
a Greek player and a Cypriot club.
12. At this point, the Single Judge acknowledged that in the claim at hand the Player requested
to be awarded outstanding salaries per the Contract and the IRA. Regarding the latter, the
Single Judge recalled that, in principle, and according to the longstanding jurisprudence of
the Football Tribunal, FIFA is not competent to decide on agreements in which the subject
matter is the license of image rights, as those are not employment-related agreements.
However, the Single Judge highlighted that also in line with the Football Tribunal’s
jurisprudence, such conclusion might be different if specific elements of the separate
agreement suggest that it was in fact meant to be part of the actual employment
relationship. Therefore, image rights agreements shall be assessed on a case-by-case basis,
considering the particularities and specific circumstances of each individual dispute (cf.
Commentary on the Regulations on the Status and Transfer of Players, 2023 edition, p. 460462).
13. While considering the above, and ex officio, the Single Judge carefully analysed the wording
of the IRA and confirmed that it had indeed a hidden employment-related nature as
described by the jurisprudence of the Football Tribunal. In particular, the Single Judge
deemed that the following elements in the present case corroborated that the IRA was in
fact meant to be part of the actual employment relationship along with the Contract:
a.

The IRA expressly stated that the Player agreed to assign his image rights during his
employment, therefore implying the IRA was integral to the Player’s employment
relationship with the Club.

The IRA was concluded by the same parties, on the same date and for the same
duration as the Contract.

pg. 6

REF. FPSD-20986

The termination of the IRA was directly linked to the employment relationship
between the parties.

The Contract entitled the Player to low remuneration (i.e., EUR 500 net per month)
and the IRA was much more lucrative for the Player (i.e., EUR 11,700 under Annexe 1
of the IRA for the 2024/2025 season, i.e., EUR 1,300 per month), which could also be
interpreted as a sign that the IRA was a supplementary agreement to the Contract.

Annexe 1 of the IRA granted bonuses for the Player’s performance in the Club’s
matches, which was typical of an employment contract and integral to the football
services / employment performance of the Player.

Annexe 1 of the IRA included employment-related payments such as flight tickets,
personal allowance, accommodation, a car and five dinners per week.

14. Moreover, the Single Judge duly emphasized that the Club did not dispute the jurisdiction
of FIFA over the IRA.
15. Consequently, the Single Judge confirmed that the IRA was accessory to the Contract, hence
shall be entertained together for the purpose of the dispute at hand. It followed, in the
Single Judge’s view, that the Football Tribunal has jurisdiction over the dispute at stake in
its entirety (cf., art. 22, par. 1, lit. b) of the Regulations).
16. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, he confirmed that, in accordance with art. 29 of
the Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand
as to the substance.
b. Burden of proof
17. The Single Judge recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which he may
consider evidence not filed by the parties, including without limitation the evidence
generated by or within the Transfer Matching System (TMS).
c. Merits of the dispute
18. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the

pg. 7

REF. FPSD-20986

documentation on file. However, the Single Judge emphasised that in the following
considerations he will refer only to the facts, arguments and documentary evidence, which
he considered pertinent for assessing the matter at hand.
i. Main legal discussion and considerations
19. The Single Judge then moved to the substance of the matter and took note of the fact that
this is a claim for overdue payables arising from the Contract and the IRA by the Player
against the Club.
20. In this regard, the Single Judge observed that, according to the Player, the Club failed to
remit several monthly instalments arising from the aforementioned agreements. In
particular, the Single Judge noted that the Player claimed to be entitled to the following
amounts:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.

21. The Single Judge noted that the Club has not responded to the claim and, therefore, any
award must be made solely on the basis of the evidence provided by the Player (cf., art. 21,
par. 1 of the Procedural Rules).
22. In this context, the Single Judge acknowledged that his task was to determine, based on
the evidence presented by the parties, whether the claimed amounts under the Contract
and IRA had in fact remained unpaid by the Club and, if so, whether the latter had a valid
justification for not having complied with its financial obligations.
23. Firstly, the Single Judge turned to analyse the monthly salaries owed to the Player under
the Contract and the IRA. In this regard, the Single Judge recalled that the Player was
entitled to receive a monthly salary of EUR 500 net under the Contract and a total payment
of EUR 11,700 under Annexe 1 of the IRA for the 2024/2025 season, i.e., EUR 1,300 per
month (EUR 11,700 divided by 9 months between August 2024 and April 2025). Further, the

pg. 8

REF. FPSD-20986

Single Judge noted that as per Annexe 1 of the IRA, the Player was entitled to an additional
EUR 400 per month for the months of January to April in the 2024/2025 season “in the event
that [the Club] participates in Group A”.
24. In this context, the Single Judge observed that the Player requested EUR 1,200 net as part
of the salary for February, of which EUR 400 corresponded to the additional payment under
Annexe 1 of the IRA and the remaining amount corresponded to the partial salary for that
month, i.e. EUR 800 out of EUR 1,800 (EUR 500 under the Contract plus EUR 1,300 under
the IRA). Furthermore, the Player requested EUR 2,200 net for March and April 2025, of
which EUR 400 corresponded to the additional payment under Annexe 1 of the IRA and the
remaining amount corresponded to the full monthly salaries under the Contract and the
IRA, i.e. EUR 1,800.
25. Regarding the salaries under the Contract and the IRA (EUR 1,800), the Single Judge
observed that in the case at hand the Club bore the burden of proving that it indeed
complied with the financial terms of the Contract and IRA concluded between the parties.
However, the Single Judge highlighted that the Club failed to respond to the claim and,
therefore, it was undisputed that the claimed amounts remained unpaid. Hence, the Single
Judge decided to award the Player EUR 800 for February and EUR 1,800 each for March and
April 2025, as requested.
26. The Single Judge then noted that with respect to the additional EUR 400 payments
requested under Annexe 1 of the IRA, the Player has submitted evidence that in January
2025, the Club qualified to participate in the First Groups play-offs. However, the Single
Judge observed that the evidence provided by the Player did not specify the nature of the
matches in January 2025 or whether the Club indeed qualified to “Group A” as required
under Annexe 1 of the IRA. Further, the Single Judge emphasized that the Player has not
provided any evidence that the Club has made any previous payment(s) of the additional
EUR 400 for the month of January 2025. Therefore, the Single Judge rejected the claim for
the additional EUR 400 per month under the IRA for the months of February to April 2025,
as the Player failed to discharge his burden of proof under art. 13 par. 5 of the Procedural
Rules.
27. Secondly, the Single Judge turned to analyse the claim of the Player for a personal
allowance of EUR 150 net per month between August 2024 and April 2025 as per Annexe 1
of the IRA. However, the Single Judge recalled that Annexe 1 of the IRA provides as follows,
quoted verbatim:
“

“

THE CLUB SHALL PROVE THE PLAYER WITH 150 EURO TO COVER
PERSONAL EXPENSES.

150

pg. 9

REF. FPSD-20986

28. In analysing the above provision, the Single Judge was of the opinion that the Player was
entitled to a single payment of EUR 150 to cover personal expenses, and the contractual
provision did not provide a monthly payment in this regard. The Single Judge further
highlighted that the Player has not provided any evidence of such previous payments of
personal allowance made by the Club or that such payment was to be construed as a
monthly payment. Therefore, the Single Judge decided to award the Player EUR 150 as
personal allowance.
29. Lastly, the Single Judge noted that the Player has claimed EUR 80 as bonuses under Annexe
1 of the IRA as follows:
a.

EUR 50 for scoring a goal that led to a win on 22 November 2024.

EUR 30 for providing an assist that led to a win on 26 October 2024.

30. In this regard, the Single Judge acknowledged that the Player has submitted evidence of
the goal and assist provided by the Player in the Club’s wins and as these remained
undisputed by the Club, the Single Judge was of the opinion that the above bonuses be
awarded to the Player.
31. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, and in accordance with the general legal principle of pacta sunt
servanda, the Single Judge decided that the Respondent must pay the following amounts
to the Player:
a.

EUR 3,600 for the months of March and April 2025 under the Contract and IRA, i.e.,
EUR 500 under the Contract, plus EUR 1,300 (i.e., EUR 11,700 divided by 9 months
between August 2024 and April 2025) under Annexe 1 of the IRA totaling EUR 1,800
per month.

EUR 800 as part salary for the month of February 2025.

EUR 150 as personal allowance.

EUR 80 as bonuses for one goal and one assist under Annexe 1 of the IRA.

32. Lastly, taking into consideration the Claimant’s request as well as the constant practice of
the Football Tribunal in this regard, the Single Judge decided to award the Claimant interest
on said compensation at the rate of 5% p.a. as of 23 September 2025 until the date of
effective payment.
ii. Art. 12bis of the Regulations

pg. 10

REF. FPSD-20986

33. The Single Judge then referred to art.12bis par. 2 of the Regulations, which stipulates that
any club found to have delayed a due payment for more than 30 days without a prima facie
contractual basis may be sanctioned, in accordance with art. 12bis par. 4 of the Regulations.
34. To this end, the Single Judge confirmed that the Claimant put the Respondent in default of
payment of the amounts sought, which had fallen due for more than 30 days, and granted
the Respondent with at least 10 days to cure such breach of contract.
35. Accordingly, the Single Judge also confirmed that the Respondent had delayed a due
payment without a prima facie contractual basis. It followed that the criteria enshrined in
art. 12bis of the Regulations were met in the case at hand.
36. The Single Judge further established that, by virtue of art. 12bis par. 4 of the Regulations
the Single Judge has competence to impose sanctions on the club. On account of the above
and bearing in mind that this is the second offense by the Respondent within the last two
years, the Single Judge decided to impose a reprimand on the Respondent in accordance
with art. 12bis par. 4 lit. b) of the Regulations.
37. The Single Judge also highlighted that a repeated offence will be considered as an
aggravating circumstance and lead to more severe penalty, in accordance with art. 12bis
par. 6 of the Regulations.
iii. Compliance with monetary decisions
38. Finally, taking into account the applicable Regulations, the Single Judge referred to art. 24
par. 1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA
deciding body shall also rule on the consequences deriving from the failure of the
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
39. In this regard, the Single Judge highlighted that, against clubs, the consequence of the
failure to pay the relevant amounts in due time shall consist of a ban from registering any
new players, either nationally or internationally, up until the due amounts are paid. The
overall maximum duration of the registration ban shall be of up to three entire and
consecutive registration periods.
40. Therefore, bearing in mind the above, the Single Judge decided that the Respondent must
pay the full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, a ban from
registering any new players, either nationally or internationally, for the maximum duration
of three entire and consecutive registration periods shall become immediately effective on
the Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.

pg. 11

REF. FPSD-20986

41. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
42. The Single Judge recalled that the above-mentioned ban will be lifted immediately and prior
to its complete serving upon payment of the due amounts, in accordance with art. 24 par.
8 of the Regulations.
d. Costs
43. The Single Judge referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Single Judge decided that no procedural costs were to be
imposed on the parties.
44. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
45. Lastly, the Single Judge concluded his deliberations by rejecting any other requests for
relief made by any of the parties.

pg. 12

REF. FPSD-20986

IV. Decision of the Dispute Resolution Chamber
1.

The claim of the Claimant, Spyridon Glynos, is partially accepted.

The Respondent, Paeek Kerineias, must pay to the Claimant the following amount(s):
- EUR 4,630 as outstanding remuneration plus 5% interest p.a. as from 23 September
2025 until the date of effective payment.

Any further claims of the Claimant are rejected.

A reprimand is imposed on the Respondent.

Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.

Pursuant to art. 24 of the Regulations on the Status and Transfer of Players, if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent shall be banned from registering any new players, either nationally or
internationally, up until the due amount is paid. The maximum duration of the ban shall
be of up to three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary Committee
in the event that full payment (including all applicable interest) is still not made by the
end of the three entire and consecutive registration periods.

The consequences shall only be enforced at the request of the Claimant in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.

This decision is rendered without costs.

For the Football Tribunal:

Emilio García Silvero
Chief Legal & Compliance Officer

pg. 13

REF. FPSD-20986

NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777

pg. 14